On June 15, 2018, the U.S. Court of Appeals for the Sixth Circuit affirmed a decision of the U.S. District Court for the Eastern District of Michigan, holding that rents collected by a receiver during the redemption period following a non-judicial foreclosure are property of the lender, even if the borrower ultimately redeems the property.1 In 2015, the lender obtained, over the borrower's objection, a receiver for a troubled mobile home park in the Detroit area. The property was foreclosed in 2016.
